This ruling overturned the government's argument that the "innocent owner" defense may be used only by purchasers of property who had no prior relationship with the criminal suspect. The Court relied on the unqualified term "owner" to uphold the appeals court determination that the innocent owners defense is not limited to independent property purchasers. The Court also rejected the government's claim that the government owns a property at the moment illegal proceeds are used to buy it, but held that the government is the owner only when a judgment of forfeiture is won. In another ruling, United States v. Dunnigan, the Court ruled that a defendant's sentence may be extended under Federal sentencing guidelines if the jury determines he committed perjury at trial. The Court stated that perjury is included in the "impede or obstruct the administration of justice" clause of the guidelines. In Negonsott v. Samuels, the Court ruled that the Kansas Act gives Kansas courts concurrent jurisdiction with Federal courts to prosecute certain crimes committed by or against Indians on Indian reservations.